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Report Contributors: Jaya Brooks
Ganesa Curley
Jeffrey Harris
Lauretta Joseph
Alton Reid
Abbreviations
EPA U.S. Environmental Protection Agency
NADB North American Development Bank
OIG Office of Inspector General
OITA Office of International and Tribal Affairs
Cover Photo: Tijuana River National Estuarine Research Reserve. (EPA OIG photo)
Are you aware of fraud, waste or abuse in an
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Washington, D.C. 20460
(888) 546-8740
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OIG Hotline@epa.gov
Learn more about our OIG Hotline.
EPA Office of Inspector General
1200 Pennsylvania Avenue, NW (2410T)
Washington, D.C. 20460
(202) 566-2391
www.epa.gov/oiq
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U.S. Environmental Protection Agency
Office of Inspector General
At a Glance
20-P-0083
February 18, 2020
Why We Did This Project
The U.S. Environmental
Protection Agency Office of
Inspector General conducted
this audit to determine whether
the Border 2020: U.S.-Mexico
Environmental Program
(Border 2020 Program)
management controls are
sufficient to verify that program
activities are completed, are
linked to the accomplishment of
program objectives, and
demonstrate progress toward
achieving the program's
environmental and public
health goals and objectives.
The Border 2020 Program is an
eight-year binational effort
between the United States and
Mexico designed to "protect the
environment and public health
in the U.S.-Mexico Border
region." The Border 2020
Program aims to improve
environmental conditions in
underserved communities and
sensitive populations by
fulfilling its five goals and
associated objectives. The
program's objectives and goals
are implemented by the
environmental authorities of the
United States and Mexico.
This report addresses the
following:
• Operating efficiently and
effectively.
• Partnering with states and
other stakeholders.
Address inquiries to our public
affairs office at (202) 566-2391 or
OIG WEBCOMMENTS@epa.gov.
List of OIG reports.
Management Controls Needed to Verify and
Report Border 2020 Program
Accomplishments
What We Found
The EPA's implementation of the Border 2020
Program management controls is not sufficient
to verify that the EPA Border 2020 Program
activities are completed, are linked to the
accomplishment of program objectives, and
demonstrate progress toward achieving the
program's environmental and public health
goals and objectives. Although a varied set of documents has been developed to
share the contributions of individual projects to Border 2020 Program goals and
objectives, we found that essential documentation on Border 2020 Program
activities was frequently unreliable.
Border 2020 Program
successes in improving
environmental conditions and
public health cannot be fully
known or documented
without stronger
management controls.
According to the EPA, Border 2020 Program reports should provide information
on the status and trends of environmental quality in the U.S.-Mexico border
region using the EPA-determined output-based indicators. However, we found
that the most recent indicator report was developed in 2016 and was only
published as an interim report. The Border 2020 Program is not planning to
create any additional reports on environmental quality at the border because it
lacks sufficient resources.
The EPA's Strategic Plan and the Border 2020 Program Communications
Strategy emphasize sharing information about Border 2020 Program-funded
products, such as reports, studies, videos, and other tools, or environmental
outcomes with its external stakeholders and the public. Sharing these products
help track the program's actions and accomplishments. We found that the EPA
has not shared many of these products and results from program-funded
projects; thus, the status of the Border 2020 Program's activities is neither
transparent nor accessible.
Without sufficient management controls for the Border 2020 Program, the EPA
cannot verify whether the program is achieving its intended purpose to protect
the human health and environment as it relates to the U.S.-Mexico border.
Recommendations and Planned Agency Corrective Actions
We recommend that the EPA establish and implement management controls to
(1) increase the reliability of action plans by standardizing the format and to
determine how and when Policy Forums action plans will be developed;
(2) develop performance measures; (3) share subgrantee fact sheets; and
(4) provide stakeholder and public access to funded products such as studies,
reports, and videos. The Agency agreed with our recommendations and provided
acceptable corrective actions.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
THE INSPECTOR GENERAL
February 18, 2020
MEMORANDUM
SUBJECT: Management Controls Needed to Verify and Report Border 2020 Program
Accompli shments
Report No. 20-P-0083
FROM: Sean W. O'Donnell
LSm.
/(?rm
,/
TO:
W.C. Mcintosh, Assistant Administrator
Office of International and Tribal Affairs
This is our report on the subject audit conducted by the Office of Inspector General of the
U.S. Environmental Protection Agency. The project number for this audit is OA&E-FY19-0245. This
report contains findings that describe the problems the OIG has identified and corrective actions the OIG
recommends. This report represents the opinion of the OIG and does not necessarily represent the final
EPA position.
The Office of International and Tribal Affairs is responsible for the findings outlined in this report.
In accordance with EPA Manual 2750, your office provided acceptable corrective actions and milestone
dates in response to OIG recommendations. All recommendations are resolved and no final response to
this report is required. However, if you submit a response, it will be posted on the OIG's website, along
with our memorandum commenting on your response. Your response should be provided as an Adobe
PDF file that complies with the accessibility requirements of Section 508 of the Rehabilitation Act of
1973, as amended. The final response should not contain data that you do not want to be released to the
public. If your response contains such data, you should identify the data for redaction or removal along
with corresponding justification.
We will post this report to our website at www.epa.gov/oig.
-------
Management Controls Needed to Verify and 20-P-0083
Report Border 2020 Program Accomplishments
Table of C
Purpose 1
Background 1
Scope and Methodology 6
Prior Report 7
Responsible Office 7
Results 8
Action Plan Information Is Unreliable 8
Environmental Indicators Are No Longer Tracked 9
Border 2020 Program Lacks Transparency 10
Conclusions 12
Recommendations 12
Agency Response and OIG Assessment 13
Status of Recommendations and Potential Monetary Benefits 14
Appendices
A Agency Response to Draft Report 15
B Distribution 26
-------
Purpose
The Office of Inspector General conducted this audit to determine whether the
U.S. Environmental Protection Agency's management controls for the Border
2020: U.S.-Mexico Environmental Program (Border 2020 Program) are sufficient
to verify that program activities are completed, are linked to the accomplishment
of program objectives, and demonstrate progress toward achieving the program's
environmental and public health goals and objectives.
Background
The Border 2020 Program is an eight-year binational plan executed on August 8,
2012, between the United States and Mexico to "protect the environment and
public health in the U.S.-Mexico Border region." The
Border 2020 Program aims to improve environmental
conditions in underserved communities and sensitive
populations by fulfilling five goals and associated
objectives. The Border 2020 Program also "aims to
provide stakeholders timely access to environmental data
and promote training and capacity building that focuses on
environmental and programmatic sustainability within
border communities." In 1983, the United States and
Mexico signed the La Paz Agreement to facilitate
cooperation in addressing environmental problems along
the U.S.-Mexico border. Implementation of the La Paz
Cacti in Tijuana Estuary, a Border 2020 Agreement and its priorities has largely been carried out
project site. (EPA OIG photo) through the Border 2020 Program and its three prior
iterations.1
Border 2020 Program Goals and Objectives
The Border 2020 Program has a specific set of goals and objectives to protect the
environment and public health in the U.S.-Mexico border region.2 They are:
1. Reduce air pollution.
2. Improve access to clean and safe water.
1 The first binational program was the Integrated Border Environmental Plan for the U.S.-Mexico border area
established between the environmental authorities of the United States and Mexico. The next iteration of the
program was the Border XXI program, a live-year bilateral effort by the EPA and the Mexican Environment
Natural Resources Fisheries Secretariat, and the Mexican Social Development Secretariat. The Border 2012
Program was established in 2003 through negotiations and participation of the ten border states, 26 U. S. tribal
nations, the EPA. the Mexican Secretariat of Environment and Natural Resources, the U.S. Department of Health
and Human Services, and the Mexican Secretariat for Health. The Border 2012 Program was designed as a ten-year
program and emphasized a regional bottom-up approach, which incorporated local decision-making, priority setting,
and project implementation as the basis for addressing enviromnental issues in the border region.
2 Each Border 2020 Program goal lias four to five objectives. See the EPA Border 2020 Program website for a
complete list.
20-P-0083
1
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3. Promote materials management and waste management, and clean sites.
4. Enhance joint preparedness for environmental response.
5. Enhance compliance assurance and environmental stewardship.
These goals and objectives were developed based on input from stakeholders and
program partners, as well as existing environmental challenges that remain along
the border. Figure 1 depicts the U.S.-Mexico border region, which extends
approximately 2,000 miles from the Gulf of Mexico to the Pacific Ocean and
includes over 60 miles on each side of the border, impacting four states in the
United States and six states in Mexico.
Figure 1: Map of U.S.-Mexico Border Region
CALIFORNIA
ARIZONA
NEW MEXICO
BAJA
CALIF.
Pacific Ocean
Gulf of 1
California
SONORA
CHIHUAHUA »
Pre
PaurruT^'
Rincorc
Sot Pasqual-i
(jrande ¦
Barcna-
Cap-tan -
Vi«ja s H
Galfof
Mexko
COAHUILA
NUEVO
L£6N
TAMAULIPAS
BMSBSEB
Source: The EPA.
Border 2020 Program Roles and Responsibilities
Numerous national, regional, and local stakeholders contribute to the design,
planning, and implementation of the Border 2020 Program. As depicted in
Figure 2, the United States and Mexico are represented by the Office of
International and Tribal Affairs and the Mexican Secretariat of Environment and
Natural Resources, respectively.3 OITA is further supported by EPA Regions 6
and 9. The Border 2020 Program within the EPA also maintains specific staff in
two EPA border offices located within Regions 6 and 9 in El Paso, Texas, and
3 OITA is responsible for the budget of the Border 2020 Program and grant funding. According to the EPA. in fiscal
year 2019, $504,000 out of the $2,696,000 that was budgeted for the Border 2020 Program went toward Border
2020 project grants.
20-P-0083
2
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San Diego, California, respectively.4 The border offices are responsible for
outreach in the community, and they are the technical leads for each of the Border
2020 Program goals. Each country is represented on workgroups, task forces, and
five Policy Forums that address specialized policy issues.
Figure 2: Border 2020 Program roles and responsibilities
OITA is accountable for the overall Agency implementation of program
activities and the budget of the Border 2020 Program.
EPA regional offices work with headquarters and the border offices
closely to ensure that implementation of the program is occurring.
EPA border offices conduct many of the day-to-day activities for the
Border 2020 Program and are specifically responsible for outreach in
the community, development of action plans, and working with the
EPA's grantee.
|#|
The Mexican Secretariat of Environment and Natural
Resources, in conjunction with the EPA, provides guidance and
oversight to Border 2020 Program coordinating bodies.
The NADB is the EPA grantee for the Border 2020 Program and
provides oversight of Border 2020 Program subgrantees projects.
I'l
Policy Forums provide borderwide technical and policy support
on issues that are primarily of a federal nature and develop action
plans that are used to track the Border 2020 Program progress.
Regional workgroups play a large role in the development of
regional action plans that are used for tracking progress toward
programmatic goals and objectives.
Task forces are a smaller segment of the regional workgroups
that encourage local decision-making, priority-setting and project
implementation.
Source: The EPA OIG.
North American Development Bank
The Border 2020 Program initiates projects primarily by issuing grants. The
grants that are funded by OITA are conducted through a single grantee that then
provides the money to individual projects, which are referred to as subgrantees.
4 In fiscal year 2019, the border office in Region 6 had 4.9 full-time equivalents (including one border office
director) and the Region 9 border office had 3.7 full-time equivalents (including one border office director) who
worked with their Mexican counterparts in regional workgroups. For Region 6, the workgroups included the Texas-
New Mexico-Chihuahua workgroup and the Texas-Tamaulipas-Nuevo Leon-Coahuila workgroup. For Region 9, the
workgroups included the Arizona-Sonora workgroup and the California-Baja California workgroup.
20-P-0083
3
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The North American Development Bank is the sole EPA grantee for the Border
2020 Program. To facilitate the relationship, the EPA has cooperative agreements
with the NADB to manage funds and facilitate projects associated with the Border
2020 Program.5 The NADB maintains all the subgrantee records, which include,
but are not limited to, fact sheets, work plans, quality assurance project plans, and
technical assistance agreements associated with the projects. The NADB uses a
file sharing service to give the EPA access to all the subgrantee records.
Border 2020 Program Project Process
After the cooperative agreements between the EPA and the NADB are complete,
the project planning process begins for the Border 2020 Program. The regions, the
NADB, and border offices lead the effort to develop gap analyses to determine
where the Border 2020 Program objectives are not being met and where more
projects are needed. As depicted in Figure 3, the gap analyses are used to support
the development of the requests for proposal for Border 2020 Program projects.
The regions, border offices, and the NADB work together to develop requests for
proposal that meet Border 2020 Program project needs. According to the EPA, the
NADB, with consensus from EPA staff, selects the Border 2020 Program
subgrantee projects.
Figure 3: Border 2020 Program planning process
EPA/NADB
Cooperative
Agreements
Gap
Analyses
Produced
Action Plans
Developed
Requests
for Proposal
Source: The EPA OIG.
Work plans are developed for each project once they are selected, as a part of the
NADB's oversight. The work plans outline the activities, priorities, and criteria
that will be completed and used during the duration of the project. The NADB,
5 Cooperative agreements are documents that outline the project title and description project period and budget, and
administrative and programmatic conditions. The NADB is responsible for dispersing the funds and oversight of the
subgrantee. The EPA participates in the selection of subgrantees; however, the NADB has the final decision on
which projects receive funding based on the criteria set forth by the Border 2020 Program.
20-P-0083
4
-------
the EPA, and the subgrantee must agree on the work plan. The work plans are
completed in the beginning of the grant cycle, and they are used by the Border
2020 Program staff and the NADB throughout the project life cycle to determine
whether the projects are on track. The projects are also added to the regional
action plans, which are overall Border 2020 Program planning and tracking
documents developed by the regions, border offices, and regional workgroups
with input from the Policy Forums.
Action Plans
Border 2020 Program action plans serve as management controls to outline
priorities and implementation strategies to accomplish the various goals and
objectives based on available resources, emerging issues, and regional and
community priorities.6 The action plans are designed to align with Border 2020
Program goals and objectives and summarize the accomplishments of the
previous two years. According to the Border 2020 Program, action plans should
provide concrete activities, time frames, outputs, and outcomes that support and
measure progress towards achieving the program's goals and objectives.
Action plans are developed by the border offices, Region 6, Region 9, and the
Policy Forums in conjunction with the regional workgroups. These action plans
are shared on the EPA's Border 2020 Program website, and serve as a resource to
evaluate program effectiveness and identify priority projects and efforts.
Border 2020 Program Communication Strategy
The Border 2020 Program implemented the Communication Strategy for Border
2020, dated February 2013, to inform stakeholders and the public of its activities
that serve the border region. The strategy states:
Effective communication is critical to the success of the U.S. -
Mexico Environmental Program: Border 2020, a program in which
border stakeholders, and federal, state and local governments
collaborate to identify and discuss environmental and public health
protection in the border region. Therefore, through this
Communication Strategy Border 2020 will emphasize the
importance of communication so that border stakeholders are well
informed, engaged, and committed to Border program activities.
6 Written processes, policies, and procedures—which are collectively called internal management controls—are
how federal agencies demonstrate that they implement laws and regulations consistently and effectively. OMB
Circular A-123, Management's Responsibility for Enterprise Risk Management and Internal Control, requires
federal agencies to develop internal control systems, document the internal control processes of the organization,
and engage in ongoing monitoring and evaluations to identify internal control issues. All federal agencies and
offices are expected, under the requirements of the circular, to create written policies and procedures to demonstrate
that their programs are implemented consistently, effectively, and efficiently.
20-P-0083
5
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The EPA's website for the Border 2020 Program contains several types of
publications that provide information on progress toward goals and detail specific
project accomplishments. Highlights Reports, newsletters, and indicator reports
are all mechanisms that are used to share information with stakeholders. The
Border 2020 Program developed the following timeline (Figure 4) to depict when
each item is scheduled to be shared with the public.
Figure 4: Border 2020 Program accountability and reporting*
2014
2013
2017
2019
2020
c_
UJ
wwO
%<2
2016
2018
2015
Source: Border 2020 Program.
*Newsletters are not included but are required twice a year, according to the Border 2020
Program Communication Strategy.
Scope and Methodology
We performed our work from July to December 2019. We conducted this
performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain
sufficient, appropriate evidence to provide a reasonable basis for our findings and
conclusions based on our audit objective. We believe that the evidence obtained
provides a reasonable basis for our findings and conclusions based on our audit
objective.
This audit assesses whether the performance of the Border 2020 Program
management controls is sufficient to verify that program activities are completed,
are linked to the accomplishment of program objectives, and demonstrate
progress toward achieving the program's environmental and public health goals
and objectives. We conducted meetings with program staff, regional staff, the
NADB, and select subgrantees.
20-P-0083
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In addition to applicable Border 2020 Program policies and procedures, we
reviewed:
• Relevant EPA policies and procedures.
• The Fiscal Year 2018-2021 Strategic Plan.
• Region 6 and Region 9 action plans from 2013 through 2018.
• NADB project work plans and fact sheets from 2013 through 2017.
• 2013 Policy Forums action plans.
• Border 2020 Program Summary.
• Border 2020 Program Communication Strategy.
• Region 6 and Region 9 gap analyses.
• Highlights Reports from 2016 through 2018.
• 2016 Interim Indicator Report.
• Regional newsletters from 2013 through 2018.
• Program budget and full-time equivalent analysis from 2013 through
the present.
In addition, we obtained and analyzed grant records, including internal work plans
and final fact sheets, for a judgmental sample of 29 Border 2020 Program projects
that were completed between 2013 to 2019. We conducted two site visits—one
each in Region 6 and Region 9—where we visited completed Border 2020
Program projects. We also attended the San Diego-Tijuana Air Quality Task
Force meeting in September 2019.
Prior Report
OIG Report No. 08-P-0245. Border 2012 Program Needs to Improve Program
Management to Ensure Results, was issued on September 3, 2008. The OIG
examined the impact of the Border 2012 Program's management and organization
on its ability to meet the program's mission. The report found that the Border
2012 Program lacked a systematic roadmap that defined the relationships between
resources, activities, and intended outcomes, and that performance measures
focused on outputs rather than outcomes. The OIG recommended that the Agency
develop a strategic plan, issue guidance to better support program results, improve
performance measures, and develop criteria for determining what constitutes
successful completion of program goals. The Agency concurred with all
recommendations, and all corrective actions have been completed.
Responsible Office
OITA is responsible for the issues discussed in this report.
20-P-0083
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Results
The EPA's implementation of Border 2020 Program management controls is not
sufficient to verify that the program's activities are completed, are linked to the
accomplishment of program objectives, and demonstrate progress toward
achieving the program's environmental and public health goals and objectives.
Although a varied set of documents has been developed to share the contributions
of individual projects to Border 2020 Program goals and objectives, we found that
essential documentation on the program's activities was frequently unreliable.
Moreover, we found that, contrary to the EPA's Strategic Plan and the Border
2020 Program Communication Strategy, the EPA has not shared many Border
2020 Program funded products externally, such as studies and reports, that would
help its stakeholders and the public track the program's actions and
accomplishments. Thus, the status of Border 2020 Program activities is neither
fully transparent nor accessible to the public.
Action Plan Information Is Unreliable
According to the EPA, the Border 2020 Program action plans are designed to
describe and document program accomplishments and indicate progress toward
goals and objectives. The Border 2020 Program requires action plans for the four
regional workgroups identified in Table 1 below, plus action plans for the Policy
Forums, which address multiregional environmental issues such as water and air
pollution. However, we found that action plans are not consistently developed.
Specifically, when we reviewed actions plans from 2013 through 2018, we found
that action plans frequently differed in format, had incomplete information, and
did not provide updated information.
Table 1: Regional action plan inconsistencies
Action plans
Failure to identify
goals, objectives, or
subobjectives
Missing
grant
information
Action
plan not
finalized
Unclear
project
status
Texas-Coahuila-
Tamaulipas- Nueva
Laredo (Region 6)
X
X
X
X
Texas-New Mexico-
Chihuahua (Region 6)
X
X
X
Sonora- Arizona
(Region 9)
X
Xa
California- Baja
California (Region 9)
X
Xa
Policy Forumsb
X
X
X
X
Source: EPA OIG analysis of Border 2020 Program action plans.
a Region 9 has developed an action plan summary document that provides the status (initial,
moderate, significant, and completed) of 2017-2018 Region 9 action plan projects. This was
an internal document specific to Region 9 that is not shared externally. Region 6 and the Policy
Forums did not have a similar summary document.
b Summary of results from the available Policy Forums action plans.
20-P-0083
8
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We found multiple inconsistencies between action plans, such as a failure to
identify goals, objectives, and subobjectives; unclear project status; and missing
grant funding information. Action plans that do not detail the related objective or
subobjective make it difficult to determine the linkage between project
accomplishments and the Border 2020 Program progress. Additionally, omitting
goal language or objective language without further details on why leads to
confusion regarding what the Border 2020 Program is doing from year to year.
When asked, Border 2020 Program staff stated that goals may have been left out
because there were no projects under that goal for a particular year.
We also found that Border 2020 Program project status was reported differently
between action plans. For Region 9, project status information was listed in a
separate status column within the 2017-2018 action plan called "progress" using
four categories: "initial progress," "moderate progress," "significant progress," or
"deliverable achieved." In Region 6, project status information was included
under a column called "status" using the categories "complete," "ongoing," and
"new." However, we found that Region 6 often used an additional category called
"open" and other nonstatus specific language such as "budget management." In
both cases, no definition of the terms used was provided, and the actual status was
unclear. Additionally, we found instances when the action plan included relevant
information on project status, but it was mixed with information regarding next
steps, making it difficult to determine the actual progress of these projects. The
lack of clear and concrete language that is used consistently across action plans
makes these documents unreliable for tracking progress toward Border 2020
Program goals.
Furthermore, according to the Border 2020 Program Communication Strategy, all
action plans, including the Policy Forums action plans, should be updated every
two years. However, we found that Policy Forums action plans have never been
updated—the 2013 draft is the only version available. Moreover, as of the
issuance of this report, all the 2013 Policy Forums action plans available on the
EPA's Border 2020 Program website are still drafts. Therefore, no recent
accomplishment data, funding amounts, or status information are provided. When
asked, Border 2020 Program staff stated that they had intended for the Policy
Forums items to be included in the regional action plans. Based on our audit, it
was unclear whether any items in the regional action plans were former Policy
Forums action plan items.
Environmental Indicators Are No Longer Tracked
The Border 2020 Program indicator reports provide information on the status and
trends of environmental quality in the U.S.-Mexico border region. However, we
found that the most recent indicator report was developed in 2016 and was
published as an interim report. As a result, available Border 2020 Program
indicator data are limited to the time frame of the 2016 Interim Indicator Report.
We also found that no further data or reports related to Border 2020 Program
20-P-0083
9
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indicators have been developed by the Border 2020 Program after the
2016 Interim Indicator Report was published.
Per the Border 2020 Program, a second indicator report was to be published in
2018. During interviews with OITA staff, the OIG was informed that the Border
2020 Program was not planning to create any additional indicator reports as a
means of tracking progress toward Border 2020 Program goals and objectives
because the program shifted from using outcomes (results and accomplishments)
to outputs (activities and services). OITA staff also stated that they no longer had
the resources to develop an additional indicator report. Without an additional
means to track established Border 2020 Program environmental indicators, the
program remains unable to determine whether it is accomplishing its stated goals
and objectives.
Border 2020 Program Lacks Transparency
The EPA's 2018-2022 Strategic Plan states that one objective of the Agency is to
"increase transparency and public participation." In addition, the Border 2020
Program Communication Strategy details how internal and external
communication should be executed. During our audit, the OIG found that the
Border 2020 Program can be more transparent in sharing its results with the
public and has not effectively implemented its communication strategy.
Specifically, we found that the program has not shared many Border 2020
Program products, such as reports, studies, videos, and other tools, and other
outcomes from program-funded projects. Also, available external documents
provided limited information on program progress toward goals and project
accomplishments.
Border 2020 Program Products Not Shared with the Public
The EPA does not always share many of the Border 2020 Program
accomplishments documented in internal work plans and final project fact sheets
through its website and publications. Sharing more information about each project
and their results could help the public track progress towards these goals and
objectives.
Our analysis of a sample of subgrantee internal work plans and final fact sheets
(for projects completed from 2013 through 2019) maintained by the NADB found
many examples of outputs, environmental results, and other products (studies,
mobile applications, etc.) that listed accomplishments. These products were not
readily accessible or available from the EPA's website. For example, our analysis
of 29 internal Border 2020 Program work plans identified at least ten products,
such as reports, studies, and videos, or environmental outcomes impacting the
public that were not easily identifiable or published in an EPA Border 2020
Program report, action plan, or other publication.
20-P-0083
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The EPA's most recent cooperative agreements with the NADB—dated
September 19, 2018, with Region 9 and dated August 22, 2019, with Region 6—
require the NADB to provide project performance reports with information
including (1) a comparison of actual accomplishments to the outputs/outcomes
established in the assistance agreement work plans for the project period and
(2) environmental results (when available) achieved by the subgrantee. In
addition, the Border 2020 Program Communication Strategy states that one of the
objectives is to communicate Border 2020 Program progress to an external
audience that includes federal and state organizations not directly involved with
the Border 2020 Program, potential stakeholders, academia, the private sector,
and the general public.
Border 2020 Program staff said that the project fact sheets developed by the
NADB and other internal documents were too dense with project-specific
information to share with the public. Staff members also said that they would
have to obtain permission from the NADB to use the project fact sheets or
publicize project accomplishments. However, according to the NADB, every
product provided by subgrantees, including final reports and fact sheets, can be
distributed to the public.
Although the EPA's Border 2020 Program website highlights many different
projects, it does not provide a clear cumulative way for the public to identify the
universe of funded projects, the project results, or how each of these projects
contribute to the Border 2020 Program goals and objectives.7 In addition, the
public must shuffle through a host of varying documents, such as Highlights
Reports, newsletters, action plans, and the interim indicator report, to try and
determine Border 2020 Program achievements when work plans and fact sheets
provide this information altogether (Table 2).
7 For example, EPA Region 6 developed a Geographic Information System Project Map, available on the EPA's
Border 2020 website, to showcase subgrantee projects funded by the Border 2020 Program, including a short
description, project information, and status.
20-P-0083
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Table 2: Project information available through Border 2020 Program publications
EPA
EPA
Mi
EPA
EPA
Regions 6
2016 Interim
B
NADB
Desired
action
Highlights
and 9
Indicator
k
fact
element
plans
Reports
newsletters
Report
15m
s
sheets
Goal/objective
Varies
Yes
Yes
Yes
Yes
Yes
Grant amount
Varies
Varies
Varies
No
Yes
Yes
Project
description
Yes
Select Only
Select Only
Select Only
Yes
Yes
Project status
Varies
Varies
Varies
Varies
Yes
Yes
Population
served
No
Varies
Varies
Varies
Yes
Yes
Outputs
Varies
Select Only
Select Only
Select Only
Yes
Yes
Outcomes
-
Select Only
Select Only
By Goal Only
Yes
Yes
Accessible to
the public
Yes
Yes
Yes
Yes
No
No
Source: EPA OIG analysis of Border 2020 Program documents.
By supplementing publications currently available on the Border 2020 Program
website with basic information already found in subgrantee work plans and
project fact sheets, the EPA could better communicate the program's progress,
success, and activities. Without this information, the program is less transparent
and stakeholders do not know what the EPA has funded and for what purpose.
Conclusions
The OIG recognizes that the Border 2020 Program is a unique binational
program. The EPA works in conjunction with the Mexican Secretariat of
Environment and Natural Resources to implement the Border 2020 Program goals
and objectives across the U.S.-Mexico border. Although it is a binational
program, the EPA is responsible for a significant portion of the effort, and,
therefore, has the responsibility to ensure that the program is meeting its
established goals and objectives. We found that the EPA is missing management
controls that would support its ability to demonstrate progress toward achieving
the program's environmental and public health goals and objectives. We also
found that the Border 2020 Program also faces challenges regarding transparency.
To mitigate these challenges, we concluded that the EPA needs to develop better
management controls, meaningful measures, and consistent communication to
increase the Agency's ability to manage this program.
Recommendations
To develop management controls to verify that the Border 2020 Program
activities are completed, are linked to the accomplishment of program objectives,
and demonstrate progress toward achieving the program's environmental and
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public health goals and objectives, we recommend that the Assistant
Administrator for International and Tribal Affairs:
1. Establish and implement management controls to increase reliability of the
Border 2020: U.S.-Mexico Environmental Program action plans by
standardizing the action plan format to include key data, such as the
relevant goal, objective, subobjective, requests for proposal, grant amount,
and project status.
2. Establish and implement management controls to determine how and
when Policy Forums action plans will be developed.
3. Develop performance measures to track progress toward Border 2020:
U.S.-Mexico Environmental Program goals and objectives.
4. Establish and implement management controls to increase transparency of
the Border 2020: U.S.-Mexico Environmental Program by sharing the
North American Development Bank subgrantee fact sheets on the EPA's
Border 2020 Program website.
5. Establish and implement management controls to increase transparency of
the Border 2020: U.S.-Mexico Environmental Program by providing
stakeholder and public access, as appropriate, to the program's funded
products such as studies, reports, and videos on the EPA's Border 2020
Program website.
Agency Response and OIG Assessment
The Agency agreed with our recommendations and provided planned corrective
actions, milestone dates, and comments in response to our draft report. Overall,
the Agency stated in its response that the OIG failed to recognize the complex
dynamics of the Border 2020 Program as a binational program. The Agency also
stated that the OIG failed to recognize the limitations set by grant policies and
regulations that govern the work conducted with the grantee and subgrantees. The
OIG held a meeting with the Agency and provided feedback on its planned
corrective actions. Following the meeting, the Agency provided revised planned
corrective actions for the OIG's consideration. As the Border 2020 Program ends
in 2021, all the Agency's corrective actions relate to changes that will be made in
the next iteration of the program—Border 2025. All recommendations are
resolved with corrective actions pending.
The Agency also provided comments on the draft report, and we revised the
report as we deemed appropriate. The Agency's comments are in Appendix A.
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Status of Recommendations and
Potential Monetary Benefits
RECOMMENDATIONS
Rec.
No.
Page
No.
Subject
Status1
Action Official
Planned
Completion
Date
Potential
Monetary
Benefits
(in $000s)
1
13
Establish and implement management controls to increase
reliability of the Border 2020: U.S.-Mexico Environmental
Program action plans by standardizing the action plan format to
include key data, such as the relevant goal, objective,
subobjective, requests for proposal, grant amount, and project
status.
R
Assistant Administrator for
the Office of International
and Tribal Affairs
12/31/20
2
13
Establish and implement management controls to determine how
and when Policy Forums action plans will be developed.
R
Assistant Administrator for
the Office of International
and Tribal Affairs
12/31/20
3
13
Develop performance measures to track progress toward Border
2020: U.S.-Mexico Environmental Program goals and objectives.
R
Assistant Administrator for
the Office of International
and Tribal Affairs
10/1/20
4
13
Establish and implement management controls to increase
transparency of the Border 2020: U.S.-Mexico Environmental
Program by sharing the North American Development Bank
subgrantee fact sheets on the EPA's Border 2020 Program
website.
R
Assistant Administrator for
the Office of International
and Tribal Affairs
12/31/20
5
13
Establish and implement management controls to increase
transparency of the Border 2020: U.S.-Mexico Environmental
Program by providing stakeholder and public access, as
appropriate, to the program's funded products such as studies,
reports, and videos on the EPA's Border 2020 Program website.
R
Assistant Administrator for
the Office of International
and Tribal Affairs
12/31/20
1C = Corrective action completed.
R = Recommendation resolved with corrective action pending.
U = Recommendation unresolved with resolution efforts in progress.
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Appendix A
Agency Comments to Draft Report
' ro UNITED STATES ENVIRONMENTAL PROTECTION AGENC Y
"Z-
I WASHINGTON, D.C. 20460
JAN 14 2020
Office of
International and
Tribal Affairs
MEMORANDUM
SUBJECT: Response to Draft Evaluation Report: Management Controls Needed to
Verify and Report Border 2020 Program Accomplishments - Project
No. 19-0245
FROM: W.C. Mcintosh,
Assistant Administrator
TO: Jeffrey Harris, Director
Program Evaluation, Special Studies
We are providing a written response to the findings and recommendations on the
above- mentioned report. The response raises concerns regarding the findings in
the draft report but indicates acceptance of each proposed recommendation. The
response also indicates planned completion dates for all recommendations.
If you or your staff have any questions regarding this response, please contact me at
(202) 564-6600 or Lisa Almodovar at (202) 564-640 I or almodovar.lisa@epa.gov.
Enclosure
Cc: Ken McQueen, RA Region 6
Mike Stoker, RA Region 9
Internet Address (URL) • http //www.epa gov
Recycled/Recyclable • Printed with Vegetable Oil Based Inks on 100% Postconsumer. Process Chlorine Free Recycled Paper
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Comments Prepared by the Office of International and Tribal Affairs (OITA) in
coordination w/ EPA Regions 6 and 9
Evaluation Report: Management Controls Needed to Verify and Report Border 2020
Program Accomplishments
January 14, 2020
General Comments
The OIG Report fails to recognize the complex dynamics within which the Border 2020 Program
operation. The draft report and recommendations reflect an unrealistic expectation or incomplete
understanding of the complex binational framework and relationships that must be worked through to
accomplish measurable results along the U.S.-Mexico Border.
These unacknowledged relationships significantly impact strategic planning, reporting, and
accountability in a way that the OIG report fails to recognize.
The OIG Report fails to recognize the limitations set by grants policies and regulations that govern the
work we do with the grantee and the grantee with its sub grantees. The OIG findings state that
essential documentation on Border 2020 activities is not shared, frequently unreliable, or missing.
All reports highlighted to be produced under the Border 2020 framework are on the website and
accessible to the public. Based on the Border 2020 Framework the essential documents are Highlight
Reports, Midterm Report (optional), Biennial Action Plans and Indicators. Except for the 2018 indicators
report, all the other essential documents are on the webpage for the public to view. Other documents
such as factsheets, press releases, meeting announcements as outlined in the communication strategy
(https://www.epa.gov/sites/production/files/documents/comm-strategy-b20201.pdf) posted to the
website are periodically reviewed by the Border 2020 Web staff and documents determined to be
duplicative or outdated may be archived.
Any studies and reports from the grantee and sub-grantees are governed by grants policies and
regulations.
However, as subgrantees Principal Investigators are required to present during a Task Force meeting by
including the project within the Task Force agenda. Furthermore, during the RWG (Biennial) meeting a
summary report of the number of projects per Goal and geographic area (State) is prepared and
presented.
OIG RESPONSE: One mission of the OIG is to promote the efficiency and effectiveness of
the EPA programs. Although the Border 2020 Program is a binational partnership, our audit
and recommendations focus only on the role and work of the EPA. Specifically, our report
recommendations aim to improve transparency and availability of basic information about
Border 2020 Program projects and their results, specifically that the EPA provides this
information to both program stakeholders and the general public.
Our report acknowledges that the EPA produces many reports highlighting the work and
results of this program. However, the OIG audit found that the EPA does not always share
through its website and publications many of the other Border 2020 Program accomplishments
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documented internally. Further, the general public is not able to easily identify the universe of
funded projects, their results, or how each of these projects contribute toward the Border 2020
Program goals and objectives. Supplementing what is already available on the Border 2020
Program website with basic information and results documented in subgrantee work plans and
project fact sheets could help the EPA better communicate the program's progress, success,
and activities.
Specific Comments
P. AT A GLANCE What we Found - 2nd paragraph 2nd sentence
'The Border 2020 Program is not planning to create any additional reports on environmental quality at
the border because they lack sufficient resources".
Although we are not publishing a final indicator report the program will be creating and publishing a
final highlight report to close out the Border Program and to highlight the remaining funded projects.
OIG RESPONSE: The OIG was informed during interviews with OITA staff that indicator
reports would no longer be produced due to a lack of resources. Our statement was specific to
indicator reports. According to the Border 2020 Program framework, Highlights Reports have
a different purpose and are not the same as indicator reports.
P. AT A GLANCE What we Found. - 3rd paragraph 1st sentence
"Moreover, we found that contrary to EPA's Strategic Plan and the Border 2020 Communication
Strategy, the EPA has not shared many Border 2020 products externally such as studies and reports that
would help its stakeholders track the program's actions and accomplishments."
It is our impression from the OIG report draft that OIG's staff term of "Border 2020 products"
encompass more than reports/documents as defined by our framework. All reports highlighted to be
produced under the Border 2020 framework are on the website. Any studies and reports from the
grantee and sub-grantees are governed by grants policies and are not property of EPA.
OIG RESPONSE: Our report refers to products developed as a result of Border 2020
Program subgrantee projects (studies, mobile applications, or environmental outcomes). We
modified this language in the final report. As noted above, our analysis of the EPA's grant
policies and procedures provided by Regions 6 and 9 did not identify any specific policies or
regulations that precludes the EPA from sharing additional information about Border 2020
Program projects and the results produced by subgrantees with the general public on its
website or through its publications. Moreover, in email correspondence with the OIG, staff
from the NADB stated that the EPA can distribute every product provided by subgrantees,
including final reports and fact sheets, to the public.
P.AT A GLANCE What we Found. - 3rd paragraph 2nd sentence
"Thus, the status of Border 2020 activities is neither transparent and nor accessible to the public. "
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All reports highlighted to be produced under the Border 2020 framework are on the website and
accessible to the public. Based on the Border 2020 Framework: the essential documents are Highlight
Reports, Midterm Report (optional), Biennial Action Plans and Indicators. Except for the 2018 indicators
report, all the other essential documents are on the webpage for the public to view. Other documents
such as factsheets, press releases, meeting announcements as outlined in the communication strategy
(https://www.epa.gov/sites/production/files/documents/comm-strategy-b2020 l.pdf) posted to the
website are periodically reviewed by the Border 2020 Web staff and documents determined to be
duplicative or outdated may be archived.
Any studies and reports from the grantee and sub-grantees are governed by grants policies and
regulations.
However, as subgrantees Principal Investigators are required to present during a Task Force meeting by
including the project within the Task Force agenda. Furthermore, during the RWG (Biennial) meeting a
summary report of the number of projects per Goal and geographic area (State) is prepared and
presented.
OIG RESPONSE: Our audit found that the general public is not able to easily identify the
universe of funded projects, their results, or how each of these projects contribute toward the
Border 2020 Program goals and objectives. Although the EPA's website and publications
produced under the framework are accessible, the public must sort through action plans and
different documents (Highlights Reports, newsletters, interim indicator reports, etc.) to identify
basic information about Border 2020 Program projects and achievements.
The Border 2020 Program Communication Strategy states that one of its objectives is to
communicate Border 2020 Program progress to an external audience not directly involved
with the Border 2020 Program—the general public, potential stakeholders, academia, and the
private sector. Supplementing available information with basic information from internal
documents could help the EPA could better communicate the program's progress, success, and
activities to the public.
Report-
P.01 Background, Last sentence
"The program has had three iterations since its inception in 1992."
If by inception you mean the signing of the La Paz Agreement, then it should be 1983 not 1992.
OIG RESPONSE: The OIG has modified the sentence in the final report.
P. 01 footnote
The IBEP was the first "program" not "agreement".
OIG RESPONSE: The OIG has modified the sentence in the final report.
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P.02 1st paragraph, 2nd sentence
62.14 Miles
OIG RESPONSE: The report indicates "over 60 miles," which is accurate.
P.04 2nd paragraph, 2nd sentence Border 2020 Project Process
The regions, NADB and border offices lead the effort to develop gap analyses.
OIG RESPONSE: This information is already stated within the report. No further change is
needed.
P.04 2nd paragraph, 5th sentence Border 2020 Project Process
The NADB, with consensus with EPA staff, selects the Border 2020 sub-grantee projects and then
oversees the sub-grantee/projects, in accordance with NADB's Technical Assistance Contract.
OIG RESPONSE: The OIG has modified the sentence in the final report.
P.05 1st paragraph, 2nd sentence 2020 Project Process (cont)
The work plans are completed at the beginning of the grant cycle and they are used by the Border 2020
staff and NADB frequently throughout the project life cycle to determine if the projects are on track. For
example, R6 holds bimonthly face to face meetings at the El Paso Border Office.
OIG RESPONSE: The OIG has modified the sentence in the final report. The example above
was not included in the final report.
P.07 last paragraph, 2nd sentence Results
Based on the Border 2020 Framework: the essential documents are Highlight Reports, Midterm Report
(optional), Biennial Action Plans and Indicators, which are all public documents on the Border 2020
Webpage. In addition, at each Regional Workgroup or Taskforce Meeting, which meets at a minimum
annually, key and ongoing activities within each reg ion are reported, including, sub-grantee reporting
on detailed progress of their projects. EPA has internal mechanisms to track progress and completion of
the subgrantee projects, as well as the gap analyses to measure completed Program Goals and
objectives.
EPA Regions follow Grant and Subgrantee Guidance and Policies with regard to sub-grantee products.
NADB is responsible for the completion of the sub-grantee projects and reports. EPA ensures that a
summary of these projects is included in the Highlights Report. EPA Reg ion 6 developed a GIS Project
Map, available on B2020 website, to showcase each of the subgrantee projects funded since the
beginning of the Border 2020 Program, including a short description and key relevant project
information and status (https://www.epa.gov/border2020/projects - funded-under-border-2020-
program-along-borders-epa-region-6-states-tx-nm).
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OIG RESPONSE: The last sentence of the paragraph states that the "EPA has not shared
many Border 2020 Program funded products externally." The OIG recognizes that there are
funded products that the Border 2020 Program has shared with the public, in particular,
through the Region 6 Geographic Information System map.
P.08 2nd paragraph, 5th sentence - Action Plan Information is Unreliable "Specifically, when we
reviewed action plans for 2013-2018, we found that action plans frequently differed in format, had
incomplete information and did not provide updated information."
For clarification: The two R6 action plans are similar and meet what is defined in the Border 2020
Framework page 40. Items may vary related to geographic areas and are at the discretion of the RWG
Chair's direction.
OIG RESPONSE: As stated in the report, we found inconsistencies between action plans
including ones within the same region. Additionally, during the course of the audit, we were
not informed, nor did we find any indication, that action plans are at the discretion of the
Regional Work Group chair.
P.08 last paragraph, 2nd sentence - Action Plan Information is Unreliable
"These included a failure to identify goals, objectives and sub-objectives, unclear project status and
missing grant funding information."
For clarification: R6 Action plans omitted sub-objectives in those areas which they are not applicable to
(i.e. Goal 1 there are no air sheds in the 4-state region), or where there were no funded projects during
the two-year period. Also, funding information is only provided for EPA/NADB Border funded projects.
For partner-funded projects, the information is le ft blank. This will be clarified in future action plans.
OIG RESPONSE: The OIG agrees with the EPA's proposal to clarify omitted information in
future action plans.
P.08 last paragraph, 3rd sentence -Action Plan Information is Unreliable
"Additionally, omitting goal language or objective language without further details on why leads to
confusion regarding what the Border 2020 Program is doing from year to year".
As stated in the previous comment, R6 Action plans only list Goals and Objectives that have a Border
funded project associated. Additional information will be added to future action plans to clarify this
practice and emphasize that Goals and Objectives language within the Action Plans are not re-written;
what it is updated are measures or projects for the duration of the 2-Year Action Plans.
OIG RESPONSE: The OIG agrees with the EPA's proposal to clarify omitted information in
future action plans.
P.09 2nd paragraph, Border 2020 Program Lacks Transparency
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"EPA's 2018- 2022 Strategic Plan states that one objective of the program is to " increase transparency
and public participation." In addition, the Border 2020 Communication Strategy detailed how internal
and external communication should be executed. During our review, the OIG found that the Border
2020 Program is not transparent in sharing its results and has not effectively implemented its
communication strategy. Specifically, we found that the program does not provide access to Border
2020 products (such as reports, studies, videos, and other tools) and other outcomes from funded
projects. Also, available external documents provided limit ed information on program progress toward
goals and project accomplishments."
All reports highlighted to be produced under the Border 2020 framework are on the website and
accessible to the public. Based on the Border 2020 Framework: the essential documents are Highlight
Reports, Midterm Report (optional), Biennial Action Plans and Indicators. Except for the 2018 indicators
report, all the other essential documents are on the webpage for the public to view. Other documents
such as factsheets, press releases, meeting announcements as outlined in the communication strategy
(https://www.epa.gov/sites/production/files/documents/comm- strategy-b2020 l.pdf) posted to the
website are periodically reviewed by the Border 2020 Web staff and documents determined to be
duplicative or outdated may be archived.
Any studies and reports from the grantee and sub-grantees are governed by grants policies and
regulations.
However, as subgrantees Principal Investigators are required to present during a Task Force meeting by
including the project within the Task Force agenda. Furthermore, during the RWG (Biennial) meeting a
summary report of the number of projects per Goal and geographic area (State) is prepared and
presented.
OIG RESPONSE: The OIG modified the language in the final report. As stated previously,
our audit found that the EPA does not provide the public with easy access to Border 2020
Program products (such as reports, studies, videos, and other tools) and other outcomes from
funded projects. Although the EPA's website and publications produced under the framework
are accessible, the public must sort through action plans and different documents (Highlights
Reports, newsletters, interim indicator reports, etc.) to identify basic information about Border
2020 Program projects and achievements. As a result, the public and program stakeholders
cannot be aware of the full range of Border 2020 Program projects and accomplishments.
Sharing more information about each project and their results (from already available internal
documents) could help the public track progress towards these goals and objectives.
P.10 4th paragraph, Border 2020 Products not shared with the public
" Our review of a sample of sub-grantee internal work plans and final fact sheets (2013-2019)
maintained by the NADB found many examples of outputs, environmental results and other products
(e.g. studies, mobile applications, etc.) that listed accomplishments but were not readily accessible or
available from the EPA's website. For example, our review of29 internal Border 2020 work plans
identified at least 10 products (reports, studies, videos and other tools) or environmental outcomes
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impacting the public that were not easily identifiable or published in the EPA Border 2020 report, action
plan or other publication."
We proceed accordingly, pursuant to the NADB and EPA Cooperative Agreement Grant Contract and do
summarize each individual sub-grantee project funded or that will be funded, which is the commitment
that is out lined by EPA in the Framework Document. EPA adheres to the EPA Grant and Subgrantee
Policies and Guidances, therefore, in accordance with EPA-NADB Cooperative Agreement, NADB is
owner of these individual tools/final reports, etc. and it is up to them to determine if and how to
distribute the information submitted by subgrantees.
As previously stated, based on the Border 2020 Framework: the essential documents are Highlight
Reports, Midterm Report (optional), Biennial Action Plans and Indicators. Except for the 2018 indicators
report, all the other essential documents are on the webpage for the public to view. Other documents
such as factsheets, press releases, meeting announcements as outlined in the communication strategy
(https://www.epa.gov/sites/production/files/documents/comm- strategy-b2020 l.pdf) posted to the
website are periodically reviewed by the Border 2020 Web staff and documents determined to be
duplicative or outdated may be archived.
OIG RESPONSE: Our review found that the EPA does not always share through its website
and publications many of the Border 2020 Program accomplishments documented in internal
work plans and final project fact sheets. As a result, the public cannot be aware of the full
range of Border 2020 Program projects and accomplishments. Sharing more information about
each project and their results could help the public track progress towards these goals and
objectives. In email correspondence with the OIG, staff from the NADB stated that the EPA
can distribute every product provided by subgrantees (final reports, fact sheets, etc.) to the
public.
P. 11 First paragraph, last sentence - Border 2020 Products 1101 shared with the public " However,
according to NADB, every product provided by sub-grantee (final reports), fact sheets, etc.) can be
distributed to the public".
Note that distribution is limited pursuant to EPA's and NADB's Collaborative Agreement language with
final distribution of these products made by consensus among EPA and NADB's Project Officers. As per
NADB and their Subgrantee's contract, information is distributed to the public when the sub-grantee's
Principal Investigator presents it during the Task Force public meeting.
OITA provides the results of completed projects through summaries within the
Highlights/Accomplishments Report. These reports are available on the Border 2020 website.
OIG RESPONSE: Please see response above.
P. 11 last paragraph of page on Border 2020 Products not shared with the public
EPA R6 did publish a GIS project tracking tool that highlights geographically basic information of projects
funded under the EPA - NADB Collaborative Agreement. This GIS map include projects funded under
RFPs from FY 2013 to present.
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OIG RESPONSE: The OIG modified the final report to include a footnote regarding the
Region 6 Geographic Information System work.
P. 12, 1st Paragraph, 6th line - to end paragraph of Conclusion
"The EPA is missing management controls that would support its ability to demonstrate progress toward
achieving the program's environmental and public health goals and objectives."
We suggest the word "externally" be added to this sentence. Since we do have internal resource
mechanisms in place such as the R6's Metric Goal of completed projects, added to R6 and R9's GAP
Analyses, action plans, and R6's GIS mapping of B2020 NADB's funded projects which show progress.
OIG RESPONSE: Our audit found the need for improvements to internal and external
elements. Therefore, adding the word "externally" would be contrary to our findings and
conclusions.
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Corrective Action and Milestones Table
Revised (January 22, 2020)
OIG Comment: The EPA originally provided proposed corrective actions and milestone dates for
OIG consideration on January 14, 2020. Following a January 21, 2020, meeting between the OIG
and the Agency, the EPA provided the revised planned corrective actions presented below. We
reviewed the revised corrective actions and consider these recommendations resolved with
corrective actions pending.
#
OIG RECOMMENDATIONS
AGENCY PLANNED CORRECTIVE ACTION
MILESTONE
1
Establish and Implement
management controls to
increase reliability of Border
2020 Program action plans by
standardizing the action plan
format to include key data such
as the relevant goal, objective,
subobjective, requests for
proposal, grant amount and
project status.
OITA agrees and recognize the advantage toward
Action Plans Format standardization to establish
and implement management controls that increase
reliability of the Border program's action plans.
OITA, in coordination with NPMs and Regional
Border Offices, will develop a standard format for
the Border 2025 Action Plans that should include
key data such as; the goal, objective, subobjective,
requests for proposal, grant amounts and project
status to the extent that the key data conforms with
the new program.
Note: The developed action plans will allow for
flexibility within RWG's and Task Forces in the
spirit of fomenting the border program bottom up
work as each region may have differences.
Complete by
end of 1st
quarter FY '21
2
Establish and implement
management controls to
determine how and when Policy
Fora action plans will be
developed.
OITA agrees that there should be establish and
implementable management controls that help
determine how and when policy fora action plans
will be developed.
OITA will establish and implement management
controls for the Border 2025 program policy fora
action plans, if identified and negotiated.
Policy Fora Action/Activities are being considered
in the Accountability of the Border 2025
framework and will be reflected or include in the
regional action plans, if required.
Note: Border 2020 Policy Fora did not require
action plans. All activities of the Border 2020
Program where implemented at the regional level.
Complete by
end of 1st
quarter FY '21
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3
Develop performance measures
to track progress toward Border
2020 Program goals and
objectives.
OITA agrees that the program should have
performance measures to track progress toward the
Border Program goals and objectives.
OITA will develop Border 2025 program
performance measures in consultations with NPM's
and Regional Border Offices and in line with the
Agency LEAN effort.
Complete by
beginning of
1st quarter FY
'21
4
Establish and implement
management controls to
increase transparency of the
Border 2020 Program by
sharing North American
Development Bank sub-grantee
fact sheets on EPA's Border
2020 Program website.
OITA agrees that sharing of NADB's sub-grantees
fact sheets will increase programs transparency.
OITA, in coordination with the Regional Border
Offices, the NADB and the EPA Grants Office will
establish and implement management controls; as
allowed by the grants terms and conditions, and
grant policies and regulations, to increase sharing
of sub-grantee project such as fact sheets on the
NADB's website.
EPA will provide a link on the future Border 2025
website to those materials on NADB's website as
NADB is the grantee.
Complete by
end of 1st
quarter FY '21
5
Establish and implement
management controls to
increase transparency of the
Border 2020 Program by
providing stakeholder and
public access, as appropriate, to
border 2020 funded products
such as studies, reports and
videos on EPA's border 2020
website
OITA agrees that sharing of Border Program
funded products such as studies, reports and videos
will increase programs transparency.
OITA, in coordination with the NPM's and
Regional Border Offices will establish and
implement management controls to increase
transparency of the Border Program by providing
stakeholder and public access, as appropriate, to
Border Program funded products such as studies,
reports and videos on EPA's Border 2025 website
Note: If any of the products such as studies, reports
and videos, are from a sub-grantee or the NADB,
EPA will then provide a link on the future Border
2025 website to those materials on NADB's
website.
Complete by
end of 1st
quarter FY '21
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Distribution
The Administrator
Assistant Deputy Administrator
Associate Deputy Administrator
Chief of Staff
Deputy Chief of Staff
Agency Follow-Up Official (the CFO)
Agency Follow-Up Coordinator
General Counsel
Associate Administrator for Congressional and Intergovernmental Relations
Associate Administrator for Public Affairs
Director, Office of Continuous Improvement, Office of the Administrator
Assistant Administrator for International and Tribal Affairs
Principal Deputy Assistant Administrator for International and Tribal Affairs
Regional Administrator, Region 6
Regional Administrator, Region 9
Audit Follow-Up Coordinator, Office of the Administrator
Audit Follow-Up Coordinator, Office of International and Tribal Affairs
Audit Follow-Up Coordinator, Region 6
Audit Follow-Up Coordinator, Region 9
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